The European Accessibility Act, in plain English

No legal jargon. Just what it means for a company with a website — and, where the answer is genuinely unsettled, we say so.

What it is

The European Accessibility Act (Directive 2019/882) requires digital products and services to be usable by people with disabilities. Member states had to apply their national measures from 28 June 2025. Each state wrote it into its own law, with its own regulator and its own penalties.

One thing that is often left out: the directive allows a transitional period until 28 June 2030 for services still relying on products that were already in use before June 2025. That grace does not cover a website you can change today.

Who it applies to

It applies to businesses selling products or services to consumers in the EU. E-commerce, banking, transport, telecoms and e-books are named explicitly.

A micro-enterprise — fewer than 10 employees and annual turnover or balance sheet total no higher than €2 million — is exempt from the obligations that apply to services. Both conditions have to be true. A four-person company turning over €3 million is not exempt.

Note the limit of that exemption: it covers services. Micro-enterprises placing products on the market get guidance, not an exemption.

What it actually requires

In practice, national laws and regulators point at EN 301 549, the European accessibility standard, whose web chapter is built on WCAG 2.1 level AA. Most of it is ordinary:

• Every meaningful image has a text description
• Every button and link says what it does
• Every form field has a visible, connected label
• Text has enough contrast against its background
• The whole site can be used with a keyboard alone
• Visitors can zoom in without the layout collapsing

A technical caveat that matters if someone tells you otherwise: EN 301 549 is cited in the Official Journal under the Web Accessibility Directive, not yet under the EAA. So meeting it does not currently give you an automatic legal presumption of conformity under this Act. It remains the standard everyone is measured against in practice.

What the penalties look like

There is no single EU fine. Each country set its own, and they are not comparable to one another.

• Germany — the BFSG provides for fines of up to €100,000. Offering or providing a service that is not accessible falls in that top band; the €10,000 band covers documentation and information failures.
• Ireland — on summary conviction, a fine of up to €5,000 or six months’ imprisonment; on indictment, up to €60,000 or eighteen months. Ireland also lets an individual consumer apply to the Circuit Court for a compliance order.
• Spain — breaches feed into the existing disability-rights sanctions regime, banded at roughly €30,000, €90,000 and up to €1,000,000 for the most serious. Enforcement sits with the autonomous communities.
• Netherlands — no single EAA fine. Enforcement is split across five regulators by sector. For an online shop that is the ACM, whose general ceiling is €900,000 per violation, or 1% of annual turnover if that is higher.

Across all of them the pattern so far is the same: notification first, then an order to fix it, then money.

Is anyone actually enforcing it?

Yes, and the clearest case is French. On 4 June 2026 the Tribunal judiciaire de Caen ordered Carrefour France to make its website and app accessible within six months, with a penalty of €500 for every day it runs late. The case was brought by the associations apiDV and Droit Pluriel.

The detail worth remembering is Carrefour’s defence. It argued the site was already 71% conformant. The court rejected that outright: a shop is not partly accessible, in the same way a handrail does not cover most of the stairs.

It would be dishonest to stop there. In a parallel case on 6 May 2026, the Tribunal judiciaire de Lille held that Auchan E-Commerce was not caught by the obligation, applying a much higher turnover threshold from older French law. That decision is under appeal. Two French courts, two opposite answers, within a month of each other.

What is happening in Germany

Germany now has a live regulator. The joint market surveillance body of the sixteen Länder, the MLBF in Magdeburg, began operating in September 2025 and has been working through several hundred reports.

Separately — and this is the part that arrives fastest — private law firms began sending warning letters over BFSG breaches in August 2025, on a competition-law basis, with further waves through 2026. A letter like that can land long before any regulator writes to you.

But the honest position: no German court has yet ruled that a BFSG breach is actionable under competition law at all, and several lawyers argue those letters are defective. Anyone who tells you the legal risk is settled is guessing.

What to do about it

1. Scan your site so you know where you stand
2. Fix the critical failures first — usually a handful of template changes
3. Keep checking, because every site change can undo the work
4. Keep dated records, so you can show you acted in good faith

That last point matters more than people expect. When a complaint arrives, the difference between a warning and a penalty is often whether you can show you were already working on it.

This page is general information, not legal advice. Figures are the statutory maximums published by each member state and are not predictions of what any regulator would impose.